PERSONAL DATA PROTECTION CHARTER

This charter (hereafter referred to as “Charter”) provides information for customers or prospects (hereafter referred to as the “Customers”) of the personal data processing policy of the AARON SARL Group, whose registered office is located at Parc d'Activités de Signes, Allée de Stockholm 83870 Signes, FRANCE (hereafter referred to as the “Company”) including all its subsidiaries (including YONA, in charge of e-commerce and management of the www.americanvintage-store.com website and its sub-domains) and its affiliated companies. AARON respects its Customers’ concerns regarding the confidentiality of personal data that Customers may send to the Company.

The present Charter refers to the procedures used by the Company to process information about the Customer, which qualifies as personal (hereafter referred to as the “Data”). This detailed Charter is also intended to outline the Company’s policy regarding the treatment of Customer personal information as it pertains to the www.americanvintage-store.com website or any other website managed by “AMERICAN VINTAGE” (hereafter referred to as the “Website”).

The Charter sets out the way in which the Company uses and collects its Customers’ personal data, and informs them of the measures taken by the Company to ensure their Data is protected when they use the Website, in line with the provisions of French Act no. 78-17 of 6 January 1978 on Information Technology, Data Files and Civil Liberties (hereinafter referred as the “Information Technology and Liberties Act”), as amended by the provisions of French Act no. 2004-801 of 6 August 2004 on the protection of natural persons with regard to the processing of personal data, and the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

The Company is the data controller and has notified the French Data Protection Authority (hereinafter referred as the “CNIL”) of the collection and processing of personal customer data.

ARTICLE 1 – DATA COLLECTION

1.1. THE DATA

The Company may collect Customers’ Personal Data, particularly for the management of customer and commercial relations, prospection and the development of statistics, in addition to management of the “American Vintage Experience” loyalty program (registration, advantages, program services, management of the customer loyalty web page).

The Company may collect personal data from Customers, particularly when they sign up to the newsletter, create a customer account (in American Vintage stores / department store / outlet stores or on the www.americanvintage-store.com website and its sub-domains), fill in a contact card at the checkout or during any exchange with American Vintage teams (by telephone, in-store or by email).

Data refers to information on the Customer as a natural person, communicated voluntarily, which, regardless of the type, can be used to identify them either directly or indirectly. In order to provide an appropriate, high-quality service, unless refused by the Customer, Data collection by the Company may include Data such as the names and contact details provided by the Customer, their date of birth, preferences, leisure activities or choices associated with Company activities (commercial activities and customer relations); in addition to browsing or electronic identification data available on or via the Customer’s computer, tablet or mobile (such as “cookies” or “IP addresses”).

1.2. SOCIAL NETWORKS

The Company publishes pages with information and a presentation of its “American Vintage” brand on various social networks. The Customer may follow the Company pages on these social networks. Personal Customer information marked as public and accessible from their profile shall be accessible to the Company. The Company neither creates nor uses any database outside of these social networks from the personal information published here by the Customer.

The Company reminds Customers that social network settings give them the option of controlling and/or limiting Company access to their data if Customers wish to oppose it, including personal information published on their profile (which is publicly visible).

ARTICLE 2 – USE OF DATA

Data collected as described above is necessary to the management of the Company’s relationship with its prospects and Customers, more specifically to the management of the following automatic or manual processes:

- The management of a service relationship: monitoring of client relationships, client loyalty programs, sales prospecting, information transmission regarding the Company and its activities; management of electronic newsletter subscriptions (signing-up or unsubscribing);

- Management and processing of account access information, its rectification and the cancelling thereof;

Information required by the Company to accomplish the tasks described above is marked with an asterisk on the various Web pages or (electronic or paper) forms to be filled out. Other information is optional and helps the Company improve its services and communications to the Customer.

ARTICLE 3 – PRESERVATION AND STORAGE OF DATA

The data is preserved for the length of time necessary to the finalities for which they were collected.

The principal storage times are as follows: for Internet newsletter subscriptions, the Company preserves data as long as Customer’s subscription is active; for order processing, the Company preserves your data for the duration of the order fulfillment, and for 10 additional years, to fulfill accounting and legal obligations; for sales prospecting and with Customer’s approval, the Company preserves data for 3 years, starting at the end of last sales transaction with the Customer (meaning for example after a purchase, or after the Company’s latest attempt to reach the Customer without response). Data collected on the applicant page “www.americanvintage-store.com”, “Recruitment" menu is stored for 24 months as of the last visit to the applicant page by the Internet user.

ARTICLE 4 – COOKIES

The Website www.americanvintage-store.com and its sub-domains uses cookies. By using the Company Website, the Customer accepts that cookies will be placed on their computer, tablet or mobile, as explained below.

A cookie is a small file stored on a user's computer, designed to hold a modest amount of data specific to a particular client and website. Cookies facilitate Customers browsing and offer a higher quality customer service experience by storing information about Customers browsing history on a website. These cookies may then be stored on the user’s computer, tablet or mobile to identify him/her.

The cookies used on the Website may be placed there by the Website or by a third-party website. These cookies cannot individually identify the Internet user and their duration is strictly limited to the duration of the user’s browsing session.

The Internet user may refuse the use of cookies by adjusting his/her web browser parameters. This operation may however, in certain cases, result in the suppression of all cookies used by the browser, including those used by other websites, causing the alteration or loss of certain settings or parameters. The suppression of Cookies may modify or even limit browsing capabilities on the Website.

The Internet user may oppose the use of cookies by configuring your web browser in the following manner:

With Microsoft Internet Explorer 6.0 and later:

Click on the “Tools” menu, and then click on “Internet Options".

Click on the “Confidentiality” tab.

Select the preferred level with the use of your curser.

With Firefox :

Select “Tools”> “Options”.

Click on “Privacy”.

With Safari 3.x for Mac OS X:

Open Safari.

Choose Safari > Preferences, and then click Privacy.

In the “Block cookies” section, specify if and when Safari should accept cookies from websites. To see an explanation of the options, click the Help button (question mark).

If you want to see which websites store cookies on your computer, click Details.

ARTICLE 5 – RECIPIENTS OF DATA

The recipients of data, for all the purposes cited above (i.e. article 2), are the Administrative and Sales personnel of the parent company, the Company AARON (a limited liability company (Société à Résponsabilité Limitée under French Law) with a share capital of 150,000 Euros (€), registered on the Register of Commerce of Toulon under number 498 123 710 whose registered office is situated at Parc d'Activités de Signes, Allée de Stockholm, 83870 Signes, France). Such is also the case for the operational uses of this information, its centralization and its use for sales prospecting.

The database, centralized and managed by the Company, is accessible by the sales personnel of the Company’s points of sale located in Europe, the Middle East and Asia, just as by the headquarters offices Company’s personnel.

In any case, the Company shall not transmit any of the Data collected to any party outside its group, except in the cases outlined below: the Customer has given his/her explicit consent regarding the sharing of information; the Company must share this information with a third party (subsidiaries, affiliates, joint ventures, service providers or other partners) in order to furnish the Customer with a service specifically requested by him/her; the Company is summoned to reveal this data by a legal or administrative authority via a decision of the court, mandate, order or any other regulation in any country where it operates to share said Data; the Company transmits the data to a specific subcontractor (with whom it has entered into a non-disclosure agreement), using the data for the sole benefit of the Company; or the Company can also call upon one or more subcontractors for the purposes of data storage, support and maintenance of its IT (Information Technology) systems.

The Company shall insure that all subcontractors located outside of the European Union offer a sufficient level of protection of its Customers personal data, by entering into standard contractual agreements as outlined by the European Commission.

ARTICLE 6 – SECURITY AND CONFIDENTIALITY OF DATA

The Company has endeavored to implement technical and organizational security measures in order to preserve the confidentiality and security of its Customers processed personal data, and to prevent them from being deformed, damaged, destroyed or from being accessed by non-authorized third parties.

When Customers voluntarily provide personal data, they undertake to provide correct information that does not infringe on the interests or rights of third parties. To this end, the Company asks its Customers not to send content unrequested by a collection form or questionnaire, such as commercial information, adverts, personal creations, ideas or concepts, etc.

Furthermore, Company employees may access Personal Customer Data as part of their duties and undertake to do this with the utmost confidentiality.

However, the Company does not have full control of all risks related to operations on the Internet, and would like to bring to the attention of the Website users the possible risks inherent to its use. Information presented on the Website may be interrupted in the event of force majeure or independently of the will of the Company, or under circumstances outside of the Company’s responsibility.

Users of the www.americanvintage-store.comWebsite and its sub-domains who are under eighteen (18) years old are forbidden from sending personal data or using the public discussion forums without the consent of their parents or guardians. Users are reminded that if children provide personal data on the Website or in public discussion forums, they may receive unsolicited messages from third parties. It is therefore the responsibility of their legal guardians to ensure that they comply with the General Conditions of Use, to inform them of the risks of sharing personal data and to check how they use the Website.

ARTICLE 7 – RIGHTS OF ACCESS, CORRECTION, SUPPRESSION AND OPPOSITION TO THE TREATMENT OF DATA

7.1. RIGHTS OF ACCESS, MODIFICATION, CORRECTION AND SUPPRESSION

Pursuant to the French Act on Information Technology and Liberties of 6 January 1978, amended by the French Act of 6 August 2004 (French Code) and the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, Customers have the permanent right to access, question, modify, oppose, delete and correct any of their personal data. In order to exercise this right, the Company asks Customers to send any requests by letter to American Vintage Customer Service, Parc d'Activités de Signes, Allée de Stockholm 83870 Signes, FRANCE, or by email to contact@americanvintage-store.com

7.2. UNSUBCRIBING TO NEWSLETTER

The Website offers a free “Newsletter” service to which Customers can subscribe. This contains the latest news on the brand, its products and its loyalty programme.

Users who no longer wish to receive the Newsletter from the Company may unsubscribe at any time by clicking the following unsubscribe link at the bottom of each newsletter: Unsubscribe link.